{"operation":"document","citation":"02-0164","title":"Spartanburg Stainless Products, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-08-27","effective_on":null,"summary":"02-0164 response to Spartanburg Stainless Products, Inc concerning 178.503.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0164.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0164.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0164","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020164.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nResearch and |\nWashington, D.C. 20590\npecial Program\ndministratio\nAUG 27 2002\nMr. Scott Rosenberger\n›. O. Box 3488\nSpartanburg Stainless Products, Inc\nReference No.: 02-0164\nSpartanburg, SC 29304\nDear Mr. Rosenberger:\nThis is in response to your letter concerning marking UN specification drums under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company manufactures\nAl steel drums trom two drawn shells. You state that during the manufacturing process, when\nthe flat blank is drawn and stretched into a shell, the steel will thin in certain areas and thicken in\nothers. You reference the \"Die Makers Handbook\" which states that thinning may be as much as\n38% in the knuckle radius area. In your opinion, the tolerances found in ISO standard 3574 (see\n§ 178.503(a)(9)) are too tight and do not appear to apply to drawn shells. Specifically, you ask if\na greater tolerance is allowed how that should be reflected in the nominal thickness stamp.\nThe HMR do not recognize the \"Die Makers Handbook\" you reference in your letter. Section\n178.503(a)(9)(i) states that metal drums must be marked with the nominal thickness of the metal\nused in the body when the tolerance conforms to ISO Standard 3574. ISO 3574 dimensions\ndefine the nominal thicknesses and corresponding minimum thickness for steel sheets prior to\nsubjecting the steel to any manufacturing processes, in your case drawing and stretching the\nsheets into shells used to form drums. The minimum thickness and nominal dimensions indicated\nin ISO 3574 are not applicable for steel sheets after forming operations, such as drawing and\nstretching the steel sheet into shells, are completed. The purpose of marking the drum with the\nISO nominal thickness is to ensure safety in transportation by identifying the minimum permitted\nthickness of the drum, thereby indicating whether the drum is or is not suitable for reuse or\nreconditioning. Due to the unusual nature of your fabrication process, the drum should either be\nmarked with the actual minimum thickness measured at the thinnest part of the drum or the ISO\n3574 nominal thickness that corresponds to the measured minimum thickness.\nI hope you find this information helpful. If you have further question, please do not hesitate to\ncontact this office.\nSincerely,\nEdward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\n178.503(9)19)\n020164\n\n<<<PAGE 2>>>\n\nCorbin\npartanburg\nSTAINLESS PRODUCTS INC.\n§178.503(9X1)\nMarking\n02-0184\nMay 30, 2002\nResearch and Special Programs Administration\nAssociate Administrator for Hazardous Material Safety\n100 7\" Street, SW, Washington, DC 20590-000\nJS Department of Transportatior\nAttention: Standards DHM10\nDear Associate Administrator:\nI am witting to request a letter of interpretation on CFR 49 Section 178.505 (9) D.\nWe manufacture 1A1 drums. Our vessel sub-assembly consists of two drawn shells. For a 15 Gallon\nthicknesses of materiai, depending on the design: 0.052\", 0.059\", and 0.079\". As we all know, a flat\ndrum, the shells would be approximately 15.5\" Diameter by 10.5\" draw depth. We start with several\n\"Die Makers Handbook\" by Jerry Arnold, it states that thinning can be as much as 38% in what we call\nblank, which is drawn and stretched into a shell, will thin in certain areas and thicken in others. In the\nthe knuckle radius. The knuckle radius would be the transition between the top of the shell and the side.\n178.503 (9)(i) discusses a tolerance, for the metal used in the body, found in ISO standard 3574. This\ntoo tight for drawn shells. If a greater tolerance is allowed than that of a flat blank, how should this be\nsection does not seem to apply to drawn shells. The tolerances found in the ISO Standard 3574 are far\nreflected in our nominal thickness stamp?\nSincerely,\n=35%\n6.D322 inch\nscott Rosenberger\nQ.0aind\nMech. Engr. Tech.\nScott Rosenberger\nnomina!\n0.7.2\n173,28\nA1.21\n1036.:.\nSpartanburg, S.C. 29303\n121 Broadcast Drive\n(888)974-7500\nMailing Address: P.O. Box 3488\n(864)699-3200\nSpartanburg, S.C. 29304\nFAX (864)699-3250","truncated":false,"body_characters":4107}